urine test (Texas) · Go Syfert
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urine test in Texas

14 Texas opinions name it 2 courts 1972–2025 4 in the last five years

The cases below were cited by Texas courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (11)

CaseFollowedCited
Hays v. Stategreen
texapp · 1996 · cited in 2 Texas opinions naming this issue, 2003–2003
2 sentences

2003Id. ; Battles v. State , 626 S.W.2d 149, 150 (Tex. App.--Fort Worth 1981, no pet.); see also Hays v. State , 933 S.W.2d 659, 661 (Tex. App.--San Antonio 1996, no pet.) ("[A]ppellant's violation of probation was supported solely by his plea of true, notwithstanding the fact that the State offered nothing to rebut his defense.").

2003Id. ; Battles v. State , 626 S.W.2d 149, 150 (Tex. App.—Fort Worth 1981, no pet.); see also Hays v. State , 933 S.W.2d 659, 661 (Tex. App.—San Antonio 1996, no pet.) (“[A]ppellant's violation of probation was supported solely by his plea of true, notwithstanding the fact that the State offered nothing to rebut his defense.”).

22
Moses v. Stategreen
texcrimapp · 1979 · cited in 2 Texas opinions naming this issue, 2003–2003
2 sentences

2003Id. ; Battles v. State , 626 S.W.2d 149, 150 (Tex. App.--Fort Worth 1981, no pet.); see also Hays v. State , 933 S.W.2d 659, 661 (Tex. App.--San Antonio 1996, no pet.) ("[A]ppellant's violation of probation was supported solely by his plea of true, notwithstanding the fact that the State offered nothing to rebut his defense.").

2003See Moses v. State , 590 S.W.2d 469, 470 (Tex. Crim.

22
Battles v. Stategreen
texapp · 1981 · cited in 2 Texas opinions naming this issue, 2003–2003
2 sentences

2003Id. ; Battles v. State , 626 S.W.2d 149, 150 (Tex. App.--Fort Worth 1981, no pet.); see also Hays v. State , 933 S.W.2d 659, 661 (Tex. App.--San Antonio 1996, no pet.) ("[A]ppellant's violation of probation was supported solely by his plea of true, notwithstanding the fact that the State offered nothing to rebut his defense.").

2003Id. ; Battles v. State , 626 S.W.2d 149, 150 (Tex. App.—Fort Worth 1981, no pet.); see also Hays v. State , 933 S.W.2d 659, 661 (Tex. App.—San Antonio 1996, no pet.) (“[A]ppellant's violation of probation was supported solely by his plea of true, notwithstanding the fact that the State offered nothing to rebut his defense.”).

22
In the Interest of E.R.W.green
texapp · 2017 · cited in 1 Texas opinions naming this issue, 2025–2025
1 sentence

2025See In re E.R.W., 528 S.W.3d 251, 265 (Tex. App.—Houston [14th Dist.] 2017, no pet.) (concluding that a 9 Mother claims in her brief that the substance she took was a “perfectly legal herbal supplement from [B]luebonnet” and that she was unaware that it “would interact with her medication and make her ill.” However, as the fact finder, the trial court was free to disbelieve that the substance was an herbal supplement and could have reasonably inferred that Mother had taken an illegal substance with her medications based on evidence of Mother’s past drug use and refusal to take a urine test tha

11
in the Interest of B. C. S., a Childgreen
texapp · 2015 · cited in 1 Texas opinions naming this issue, 2025–2025
1 sentence

2025See In re E.M., 494 S.W.3d 209, 222 (Tex. App.—Waco 2015, pet. denied) (“A factfinder may reasonably infer from a parent’s refusal to take a drug test that the parent was using drugs.”); see also In re B.C.S., 479 S.W.3d 918, 925 (Tex. App.—El Paso 2015, no pet.) (“We give deference to the fact finder’s conclusions, indulge every reasonable inference from the evidence in favor of that finding, and presume the fact finder resolved any disputed facts in favor of its findings, so long as a reasonable fact finder could do so.”); see also In re E.P., No. 10-22-00086-CV, 2022 WL 2977479 , at *2 (Tex

11
in the Interest of E.M. and J.M., Childrengreen
texapp · 2015 · cited in 1 Texas opinions naming this issue, 2025–2025
2 sentences

2025See In re E.M., 494 S.W.3d 209, 222 (Tex. App.—Waco 2015, pet. denied) (“A factfinder may reasonably infer from a parent’s refusal to take a drug test that the parent was using drugs.”); see also In re B.C.S., 479 S.W.3d 918, 925 (Tex. App.—El Paso 2015, no pet.) (“We give deference to the fact finder’s conclusions, indulge every reasonable inference from the evidence in favor of that finding, and presume the fact finder resolved any disputed facts in favor of its findings, so long as a reasonable fact finder could do so.”); see also In re E.P., No. 10-22-00086-CV, 2022 WL 2977479 , at *2 (Tex

2025See In re E.M., 494 S.W.3d 209, 222 (Tex. App.—Waco 2015, pet. denied) (“A factfinder may reasonably infer from a parent’s refusal to take a drug test that the parent was using drugs.”); see also In re B.C.S., 479 S.W.3d 918, 925 (Tex. App.—El Paso 2015, no pet.) (“We give deference to the fact finder’s conclusions, indulge every reasonable inference from the evidence in favor of that finding, and presume the fact finder resolved any disputed facts in favor of its findings, so long as a reasonable fact finder could do so.”); see also In re E.P., No. 10-22-00086-CV, 2022 WL 2977479 , at *2 (Tex

11
Brennan v. Stategreen
texapp · 2009 · cited in 1 Texas opinions naming this issue, 2024–2024
1 sentence

2024See Brennan v. State, 334 S.W.3d 64, 72 (Tex. App.—Dallas 2009, no pet.).

11
In re R.J.green
texapp · 2019 · cited in 1 Texas opinions naming this issue, 2021–2021
1 sentence

2021See In re N.J.H., 575 S.W.3d at 835 (father’s single negative drug test after treatment for substance abuse did not negate prior history of drug use); see also In re R.J., 579 S.W.3d at 118 (father’s nonuse of drugs for extended period and completion of outpatient drug treatment program did not 16 disallow factfinder from inferring he was at risk of continuing substance abuse from evidence of past use).

11
in the Interest of N.J.H., Children v. Department of Family and Protective Servicesgreen
texapp · 2018 · cited in 1 Texas opinions naming this issue, 2021–2021
1 sentence

2021See In re N.J.H., 575 S.W.3d at 835 (father’s single negative drug test after treatment for substance abuse did not negate prior history of drug use); see also In re R.J., 579 S.W.3d at 118 (father’s nonuse of drugs for extended period and completion of outpatient drug treatment program did not 16 disallow factfinder from inferring he was at risk of continuing substance abuse from evidence of past use).

11
Holley v. Adamsgreen
tex · 1976 · cited in 1 Texas opinions naming this issue, 2018–2018
1 sentence

2018Holley v. Adams, 544 S.W.2d 367, 371-72 (Tex. 1976). 22 Father offered several excuses during the trial for his failure to comply with the requirements found in his family service plan.

11
Darland v. Stategreen
texcrimapp · 1979 · cited in 1 Texas opinions naming this issue, 1984–1984
1 sentence

1984Compare Darland v. State, 582 S.W.2d 452 (Tex.Cr.App.1979).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Texas. Read the followed side critically anyway.

Also cited on this issue (9)

CaseCitedYears
Davis v. Washington green
scotus · 2006
1 sentence

2024Clark, 576 U.S. at 245 ; Davis, 547 U.S. at 822 .

12024–2024
Ohio v. Clark green
scotus · 2015
1 sentence

2024Clark, 576 U.S. at 245 ; Davis, 547 U.S. at 822 .

12024–2024
Ferguson v. City of Charleston green
scotus · 2001
1 sentence

2016App. 2015) (per curiam). 6 Ferguson v. City of Charleston, 532 U.S. 67 (2001). 16 to the urine test as well as to the statement he made to medical personnel, therefore we address his arguments together.7 Unlike Villarreal, this case does not involve a situation where the State requested the medical personnel to obtain a urinalysis as part of a mandatory procedure.

12016–2016
Ex parte Hill neutral
texcrimapp · 1978
1 sentence

2015The defendant pled true to a different allegation and the appellate court made the observation that “had it (the urine test) been proven to be true, it should be remembered that proof of a single instance of the use of a drug cannot be characterized as a habit under the decisions of this court.” Garcia, 571 S.W.2d 900 .

12015–2015
Salinas v. State green
texapp · 2005
1 sentence

2010Thus, according to Casillas, the jury could have fully understood the issues in this case without Kellogg’s testimony. -9- 04-09-00227-CR As authority, Casillas cites Salinas v. State, where the appellate court held that expert testimony diagnosing sexual abuse based solely on the complaining witness’s self-reported history was an impermissible attempt to bolster the complaining witness’s credibility and a direct comment on her truthfulness. 166 S.W.3d at 371 .

12010–2010
Hernandez v. State green
texcrimapp · 2003
1 sentence

2008Id. at 28 .

12008–2008
Wilson v. State green
texapp · 1985
1 sentence

1986The court in Wilson v. State, 697 S.W.2d 83 (Tex.App.1985) (pet. requested) considered a particular urine test system.

11986–1986
Jones v. State green
texcrimapp · 1970
1 sentence

1972Levell v. State, Tex.Cr.App., 453 S.W.2d 831 ; Jones v. State, Tex.Cr.App., 453 S.W.2d 507 .

11972–1972
Levell v. State green
texcrimapp · 1970
1 sentence

1972Levell v. State, Tex.Cr.App., 453 S.W.2d 831 ; Jones v. State, Tex.Cr.App., 453 S.W.2d 507 .

11972–1972

Statutes the citing opinions construe

TX § Tex. Fam. Code § 161.001 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

MN 48 (1933–2024) OH 36 (1986–2025) CA 34 (1972–2025) OR 24 (1989–2025) NY 23 (1973–2025) GA 22 (1978–2025) TX 14 (1972–2025) IA 12 (1978–2019) IL 11 (1978–2026) FL 10 (1990–2023) PA 8 (1989–2021) ND 8 (2005–2025) MO 7 (1997–2025) NE 6 (1990–2018) LA 6 (1983–2018) CT 6 (1988–2026) WI 5 (1991–2024) IN 4 (1994–2020) NJ 4 (1993–2024) AZ 4 (1989–2014) AR 4 (1965–2017) NM 4 (1994–2017) MT 3 (2005–2016) DC 3 (1966–2012) WA 3 (2008–2016) KY 3 (2015–2024) ME 3 (2002–2019) WV 2 (2010–2023) CO 2 (1993–1993) MI 2 (1999–2014) ID 2 (2010–2012)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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